Question
Determine the residency status of the individuals in the following cases. Use the tie-breaker rules found in the Canada/U.S. tax treaty where appropriate. Case A
Determine the residency status of the individuals in the following cases. Use the tie-breaker rules found in the Canada/U.S. tax treaty where appropriate.
Case A Ty Breaker is a citizen and resident of the United States. He is a professional athlete, a successful entrepreneur, and single. In 2022, he plays for a Canadian soccer team and, as a consequence, he spends 194 days in Canada. Because of his extensive travel, he stores his few personal items in his mother’s basement and lives in short-term rentals of hotel suites in both Canada and the United States. His mother lives in Ontario.
As he is the sole shareholder of corporations in both countries, and he has office space in both Canada and the U.S. In previous years, Ty has played for a U.S. soccer team and had spent less than 100 days per year in Canada.
Step by Step Solution
3.60 Rating (161 Votes )
There are 3 Steps involved in it
Step: 1
Ty Breaker is a resident of the United States for tax purposes detailed ...Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started